Name and address of the reporting corporation,Transaction date,Transaction description,Shareholder gain recognition for exchanging stock?,Fair market value of the stock or other property received,Description of the stock or other property received "U.S. Concrete, Inc. 331 N. Main Street Euless, TX 76039",8/26/2021,Vulcan Materials Company purchased 100% of the common stock of the reporting corporation.,Yes,"$1,268,507,038 ",Cash of $74.00 per share "Birdi Investments LLC 723 East Green Street Pasadena, CA 91101",1/1/2018,A related company designated as a subsidiary,No,No par value,No par value stock "Birdi Constructors, Inc. 723 East Green Street Pasadena, CA 91101",1/1/2018,A related company designated as a subsidiary,No,No par value,No par value stock "UCAR Technology (USA) Inc. 2755 Great America Way Suite 225 Santa Clara, CA 95054",2/13/2018,"Haode Global, Inc acquired 100% of share capital of UCAR Technology (USA) Inc.",No,Left blank,Left blank "Buffalo Wild Wings, Inc. 5500 Wayzata Blvd, Suite 1600 Minneapolis, MN 55416",2/5/2018,"Acquired all the outstanding common stock of Buffalo Wild Wings, Inc.",Yes,2.5 billion,157.00 in cash per share of common stock "Vestinam, Inc. (a California Corporation) 471 Acalanes Dr. Apt 28 Sunnyvale, CA 94086",6/6/2018,Change of jurisdiction of incorporation from California to Delaware. Location moved to Washington state.,No,10,No change "KH Trucking, Inc. 1732 Islebrook Drive Orlando, FL 32824",11/27/2017,100% corporation and business transfer,No,Left blank,100% corporation and business received "Sohobricks Corporation 600 12th St Palisades Park, NJ 07650",11/6/2017,Merger between Sohobricks Corp (NJ) and Bricklink Corp (CA),No,No par value,No par value stock "The Artisan Shop, Inc. 1072 W. Madison Ave Loveland, CO 80537",1/2/2016,Left blank,No,Left blank,Left blank "Johnson Controls, Inc. P O Box 591 Attn: Tax Department X-81 Milwaukee, WI 53201-05915",9/2/2016,"On September 2, 2016, Jagara Merger Sub LLC, a limited liability company that was wholly owned, directly or indirectly, by Tyco, merged with and into JCI, with JCl as the surviving corporation (the ""merger""). In the merger, each share of JCI common stock was converted into, based upon the election of the holder of such share, prorated consideration of either (i) $5,7293 in cash and 0.8357 shares of Tyco (with cash in lieu of fractional shares), or (ii) $34.88 in cash. The merger was a taxable transaction for U.S. federal income tax purposes. Following the merger. Tyco changed its name to ""Johnson Controls International plc."" Certain holders of JCI shares that also held (actually or constructively) Tyco stock prior to the merger in certain specific proportions may have received, as a result of their ownership of Tyco stock, the cash component of their merger consideration as a dividend pursuant to Section 304(a)(1) of the Code. Such shareholders would generally be subject to different tax consequences as a result of the merger and should consult with their own tax advisors with respect to the specific tax consequences of the merger to them depending on their facts and circumstances. In particular, while the merger is not a reorganization to which Section 367(a) of the Code applies, any holders of JCI shares that are treated as having received the cash component of the merger consideration as a dividend pursuant to Section 304(a)(1) of the Code as a result of their actual or constructive ownership of Tyco and JCI shares prior to the merger could be deemed, pursuant to Section 304(a)(1) of the Code, to have contributed a portion of their JCl shares to an indirect foreign subsidiary of Tyco in a transaction to which Section 351(a) of the Code applies. Such deemed contribution could be subject to Section 367(a) of the Code. For more information, please refer to the ""Additional Information Relating to the Federal Income Tax Consequences of the Johnson Controls/Tyco Merger to Former Holders of Johnson Controls Common Stock,"" available on the JCI Investor Relations website, as well as the proxy statement, noting especially the discussion under the heading “Certain Tax Consequences of the Merger-U.S. Federal Income Tax Considerations.”",Yes,"Fair market value generally is the price at which property would change hands between a willing buyer and a willing seller, neither being under any compulsion to buy or to sell and both having reasonable knowledge of the facts. U.S. federal income tax law does not specifically prescribe how former JCI shareholders should determine the fair market value of the Tyco ordinary shares received in the merger. One possible method of determining the fair market value of one Tyco ordinary share is to use the average of the high and low trading prices on the date of the merger, which was $45.69. Using this figure, former JCI shareholders that elected to receive shares in the merger would receive cash and Tyco ordinary shares worth approximately $43.91 per share of JCI common stock exchanged in the merger (assuming no cash received in lieu of fractional shares). The total number of Tyco ordinary shares received in the merger in exchange for shares of JCl common stock was 527,445,124 (excluding fractional shares), and the total amount of cash received in the merger in exchange for shares of JCI common stock was $3,864,759,424.15 (including cash in lieu of fractional shares). Using the assumed fair market value of $45.69 above the total fair market value of the consideration received by all former JCl shareholders in the merger in exchange for their shares ofJCl common stock was $27,963,727,139.71. Other methods for determining the fair market value of Tyco ordinary shares are possible. Former JCI shareholders are not bound by the approach described above and may, in consultation with their tax advisors, use another approach.",Left blank "Blackville Solar II, LLC 3250 Ocean Park Blvd, Suite 355 Santa Monica, CA 90405",12/20/2016,Change of control,No,Left blank,Left blank "Platinum X Construction Corp. 20611 Canada Rd. Lake Forest, CA 92630",5/5/2014,"JMAC5, LLC acquired ownership of Platinum X Construction Corp. from Platinum X Group, LLC.",Yes,0,Common Stock "AMCOL Corporation 2870 Forbes Avenue Hoffman Estates, IL 60192",5/9/2014,Mineral Technologies purchased 100% of the common stock of Amcol Int’l thru an all-cash tender.,Yes,$45.75 per share,All-cash (100%) tender offer "Border Energy Gas Services, Inc. 4145 Powell Road Powell, OH 43065",8/3/2014,Qualified Stock Purchase under Section 338(h)(10),No,Left blank,Left blank "DE US, Inc. Oosterdokksstraat 80 1101 DK Amsterdam The Netherlands",6/28/2012,"On June 28, 2012, the Sara Lee Corporation, EIN 36-2089049, located at 3500 Lacey Road, Downers Grove, Illinois, 60515-5424, (""Sara Lee"") separated into two public companies (the ""separation""). The separation was effected as follows: Sara Lee distributed all of the common stock of DE US, Inc., a domestic corporation and the subsidiary that held Sara Lee's international coffee and tea business (""CoffeeCo""), to an exchange agent on behalf of the Sara Lee shareholders of record as of the close of business on June 14, 2012 (the ""record date"") in a transaction that qualified as a spin-off under section 355 (the ""distribution""). Before the distribution, Sara Lee was the common parent of DE US, Inc. Immediately after the distribution of the CoffeeCo common stock, CoffeeCo paid a $3.00 per share special dividend (the ""special dividend""). The special dividend was paid to CoffeeCo's shareholders of record as of the time immediately after the distribution of the CoffeeCo common stock. After the special dividend, CoffeeCo merged with a subsidiary of D.E MASTER BLENDERS 1753 N.V., a Dutch company (""DEMB"") in a transaction that qualified as a reorganization within the meaning of Section 368(a) (the ""merger""). After the distribution, and before the merger, the CoffeeCo was owned directly by the public shareholders. In addition, DEMB was, before the merger, a subsidiary of CoffeeCo that was newly formed in anticipation of the merger. As a result of the merger, each share of CoffeeCo common stock was exchanged for one ordinary share of DEMB. The exchange agent aggregated and sold any fractional shares of DEMB stock and distributed all of the remaining ordinary shares of DEMB, along with the proceeds from the sale of fractional shares, and the proceeds of the special dividend to the CoffeeCo shareholders. The exchange of CoffeeCo shares for DEMB shares pursuant to the merger requires U.S. Holders of CoffeeCo to recognize gain under Section 367(a). Further, any U.S. Holders that received cash in lieu of fractional shares are required to recognize gain under Section 1001. Shares of DEMB are listed and began trading on NYSE Euronext Amsterdam on July 9, 2012 under the ticker symbol ""DE."" Immediately following the separation, Sara Lee completed a 1-for-5 reverse stock split of its shares of common stock and changed its name to The Hillshire Brands Company.",Yes,"$5,829,620,885.00 ",Stock in a foreign corporation and cash in lieu of fractional shares "Lincare Holdings, Inc. 19387 US 19 North Clearwater, FL 33764",8/8/2012," Sale all com. shrs Lincare Holdings, Inc. to Linde US INC. and merger of Linde US INC into Linc",Yes,$4.8 billion,$41.50 per share in cash "Patriot Transportation Holding, Inc. 501 Riverside Ave, Ste500 Jacksonville, FL ",1/17/2011,Three –for –one Stock Split Common Record Date 1/3/11 CUSIP 70337B102,No,Left blank,Left blank "Pride International, Inc. 5847 San Felipe Ste 3300 Houston, TX 77057",5/31/2011,"At 9:19 a.m., Eastern Standard Time, on May 31, 2011, ENSCO Ventures LLC, a Delaware limited liability company (""Mergeco""), merged with and into Pride International Inc., a Delaware corporation (""Pride""). Mergeco was an indirect, whollyowned subsidiary of Ensco pIc, a public limited company organized under the laws of England and Wales (""Ensco""). Pride survived the merger as an indirect, wholly-owned subsidiary of Ensco. Each share of Pride common stock was automatically cancelled and converted into the right to receive (i) 0.4778 of an American depositary shares (""ADS"") representing one Class A Ordinary Share of Ensco, and (ii) $15.60 in cash. The limited liability company interests in Mergeco were, in the aggregate, converted into and became one thousand validly issued, fully paid and nonassessable shares of common stock of Pride, as the surviving corporation in the merger. Upon completion of the merger, Ensco indirectly owns all of the issued and outstanding shares of Pride. Accordingly, Ensco acquired control of Pride for purposes of IRS Form 8806, Information Return for Acquisition of Control of Substantial Change in Capital Structure",Yes,"Each share of Pride common stock issued and outstanding was converted to the right to receive (i) 0.4778 of an ADS representing one Class A Ordinary Share of Ensco, and (ii) $15.60 in cash. The fair market value of each ADS received by a Pride shareholder ursuanttothemergeris$53.32, determined by the closing price of ENSCOADS on May 31, 2011.",Each shareholder of Pride received 0.4778 of an ADSs representing one Class A Ordinary Share of Ensco in exchange for each share of Pride common stock. "Mentor Corporation Inc. and Subsidiaries 5425 Hollister Avenue Santa Barbara, CA 9311",1/23/2009,Cash purchase of reporting corporation by acquiring corporation,Yes,Left blank,Left blank "Rodney Company N.V. c/o Jaminco Management Corp. 555 Madison Avenue New York, NY 10022",1/24/2009,Transaction involves a deemed asset transfer pursuant to Treas Reg 1.367(b)-2(f)(2),No,Left blank,Left blank "Hungarian Telephone and Cable Corp. 1201 Third Avenue, Suite 3400 Seattle, WA 98101-3034",2/26/2009,Reorganization involving exchange of HTCC shares for Invitel Holdings shares.,Yes,"$124,000,000 ",Ordinary shares of Invitel Holdings A/S "James S. Zarr, M.D., P.C. 4601 W. 109th Street Suite 206 Overland Park, KS 66211",10/26/2009,Tax free reorganization under 368(a)(1)(F),Yes,Left blank,Left blank "Tim Hortons, Inc. (a Delaware Corporation) c/o 874 Sinclair Road Oakville, Ontario L6K 2Y1 Canada",9/28/2009,"On September 28, 2009, THI Mergeco Inc., a Delaware corporation and a wholly-owned subsidiary of Tim Hortons Inc., a corporation incorporated under the Canada Business Corporation Act (“New THI”), and wholly-owned by Tim Hortons Inc. [EIN: 51-0370507] (“THI USA”), the existing public company incorporated under the laws of the State of Delaware, merged with and into THI USA. As a result of the merger, the stockholders of THI USA had their existing common stock converted into an equal number of common shares of New THI. The fair market value of each New THI common share received by stockholders in the transaction is estimated to be USD $ 27.99 (CAD $30.60). This amount is based on the closing stock of THU USA on the New York and Toronto Stock exchanges respectively, on September 25, 2009, immediately prior to the merger and conversion on September 28, 2009, of common stock owned by stockholders of THI USA into common shares of New THI.",Yes,27.99 per share,Common shares in Tim Hortons Inc. (a Canadian Federal Corporation) "ENSCO International Incorporated 500 North Akard Suite 4300 Dallas, TX 75201-3331",12/23/2009,"At 12:01 a.m., Eastern Standard Time, on December 23, 2009, Ensco Newcastle LLC, a Delaware limited liability company (“Mergeco”), merged with and into ENSCO International Incorporated, A Delaware corporation (“Ensco Delaware”). Mergeco was an indirect, wholly-owned subsidiary of Ensco International plc, a public limited company organized under the laws of England and Wales (“Ensco UK”). Ensco Delaware survived the merger as an indirect, wholly-owned subsidiary of Ensco UK. Each share of Ensco Delaware common stock was automatically cancelled and converted into the right to receive one American depositary share (“ADS”) representing one Class A Ordinary Share of Ensco UK. Each outstanding limited liability company interest in Mergeco was converted into one share of common stock of Ensco Delaware, as the surviving corporation in the merger. Upon completion of the merger, Ensco UK indirectly (through a disregarded entity) owns all of the issued and outstanding shares of Ensco Delaware. Accordingly, Ensco UK acquired control of Ensco Delaware for purposes of IRS Form 8806, Information Return for Acquisition of Control of Substantial Change in Capital Structure.",Yes,"The fair market value of each ADS received by an Ensco Delaware shareholder pursuant to the merger is $42.18, determined by the average of the high (($42.60) and low ($41.75) selling prices of an ADS on December 23, 2009.",Each shareholder of Ensco Delaware received an ADS representing one Class A Ordinary Share of Ensco UK in exchange for each share of Ensco Delaware common stock. "Sono Variety Inc. 56 Rear North Main Street Norwalk, CT 06854",12/31/2009,Transferred assets to Sono Variety LLC. Both entities 100% owned by the same person.,Yes,"$24,128 ",Assets net of liabilities at book value "Datachem Laboratories, Inc. 2511 S West Temple Salt Lake City, UT 84115",10/31/2008,CBL purchased 100% of Datachem’s outstanding common stock as of 10/31/08.,Yes,"$11,300,000 ",Cash "Deal Maven, Inc. 1350 Broadway, Suite 2412 New York, NY 10018",1/31/2008,Cash sale of 100% of stock ,No,Left blank,Left blank